-9-
satisfied the verification requirement of section 6330(c)(1),
Yacksyzn v. Commissioner, T.C. Memo. 2002-99; cf. Nicklaus v.
Commissioner, 117 T.C. 117, 120-121 (2001). Petitioners have not
demonstrated in this proceeding any irregularity in the
assessment procedure that would raise a question about the
validity of the assessment or the information contained in Forms
4340. See Mann v. Commissioner, supra.
Second, petitioners argue that the Appeals officer made his
determination without affording them a hearing. Respondent
replies that petitioners “were given ample opportunity for a
face-to-face hearing.”
Because petitioners allege that a hearing under section 6330
was not properly held, the question arises whether this Court
should remand the case to Appeals to hold the hearing. Such a
question is the subject of Lunsford v. Commissioner, 117 T.C. 183
(2001). There, the Court declined to remand the case to Appeals
to hold a hearing at which to consider the taxpayer’s arguments.
The Court stated that the Court believed it neither “necessary or
productive” to do so because “the only arguments that * * * [the
taxpayers] presented to this Court were based on legal
propositions which we have previously rejected.” Id. at 189.
The same is true here. Apart from their contention about
being denied a hearing, petitioners’ only argument in this
proceeding, as gleaned from the allegations of error that they
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